By: WISCONSIN LAW JOURNAL STAFF//May 22, 2012//
United States Court of Appeals For the Seventh Circuit
Civil
Employment — public employment — freedom of speech
Where none of the disciplinary actions complained of were contemporaneous with a public employee’s purported protected speech, summary judgment was properly granted to the employer on his retaliation claim.
“[N]one of the employment actions that Kidwell complains about followed close on the heels of his purportedly protected speech. Moreover, the context in which these actions were taken defies any argument that they were related to his speech. Rather, it is apparent that significant intervening events—not the least of which was Kidwell’s own negative behavior—that occurred after Kidwell’s acts of purportedly protected speech were the cause of the negative or disciplinary employment actions that he received. Therefore, the timing of events in this case does not give rise to an inference that Kidwell’s speech was a motivating factor in any of the employment actions taken against him.”
Affirmed.
Appeal from the United States District Court for the Central District of Illinois, McCuskey, J., Manion, J.